EvidenceSheet
PCI DSS v4.0.1 · Req 5: Anti-Malware

5.4.1 Mechanisms detect and protect against phishing

The entity must have processes and automated mechanisms that detect phishing attacks and protect personnel from them. A combination of approaches is encouraged, for example anti-spoofing controls (DMARC, SPF, DKIM), link scrubbing and server-side anti-malware that block phishing messages before delivery, and training personnel to spot and report phishing; applying the controls across the whole organisation is recommended but not required. Applicability: the emphasis is on protecting staff who can access in-scope PCI DSS system components. Technical anti-phishing controls under this requirement are separate from security awareness training under Requirement 12.6.3.1; meeting one does not satisfy the other. This was advisory only up to 31 March 2025 and is now required and fully assessed. Objective under the customized approach: mechanisms exist that protect against, and reduce the risk from, phishing attacks. Future-dated: treated as a best practice up to 31 March 2025 and mandatory since then.

Source: PCI DSS v4.0.1, 5.4.1. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open PCI DSS v4.0.1 in the compliance library.

Version 4.0.1 is the active version; 4.0 has been retired. Appendix A1 applies only to multi-tenant service providers, A2 only to card-present POS POI terminals that still use SSL or early TLS, and A3 only when a payment brand or acquirer requires it. Which requirements apply to you follows your validation type.

4
artefacts
2
held by a system
1
at each review
easy
to go live
Cloud console / configuration management
where the evidence lives
teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.

system holds itEvidence a system already holds

  • DNS records and mail gateway settings showing DMARC, SPF and DKIM for the entity's domains · Cloud console / configuration management
  • Secure e-mail gateway or filtering configuration with phishing detection, link rewriting or sandboxing enabled · Cloud console / configuration management

periodic reviewEvidence produced at each review

  • Reports of blocked or quarantined phishing messages over the assessment period · Document repository

governing documentDocuments that govern the control

  • Documented process for personnel reporting suspected phishing and how reports are triaged · Document repository

First move

Automate the pull from your Cloud console / configuration management. Configuration snapshots and change history from the cloud console or IaC repository, diffed against the baseline.

Common gaps auditors find

Do this for your whole sheet

Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.

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5.3.5 Users cannot disable or alter anti-malware · 6.1.1 Requirement 6 policies and procedures maintained and communicated